Make
it 6-0. Recently, in United States v. Bell,
the Eighth
Circuit found that Missouri second-degree robbery is not a crime of violence. Why? Well, because “in Missouri a
defendant can be convicted of second-degree robbery when he has physical contact
with a victim but does not necessarily cause physical pain or injury.” That
quantum of force fails the Johnson
test.

If you have a case where your client has a
conviction for Missouri second-degree robbery, that conviction is not a crime
of violence or a violent felony. Check back with us later this week for more Bell
deliciousness.---From Kirk Redmond